Privacy policy

Who we are and what we do

ZoomDoc respects your privacy and is committed to protecting your personal data. This policy (together with our terms of use and service conditions applicable to you, as referred to in our terms of use) set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us when you use the website www.zoomdoc.com (the “Site”), the mobile application software available at the Site and via an app store (the “ZoomDoc App”) once you have downloaded or streamed a copy of the ZoomDoc App onto your mobile telephone, tablet or handheld device (“Device”).

ZoomDoc Limited is the data controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy policy). We are registered in England and Wales under company number 09540794 and have our registered office at 2 Chanin Mews, London NW2 4AQ. Our main trading address is also at that address. We are regulated by the Care Quality Commission and, as a limited company, are also regulated by Companies House.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our DPO Dr Kenny Livingstone at info@zoomdoc.com.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting and using the Site and ZoomDoc App you are accepting and consenting to the practices described in this policy. This policy is updated from time to time. The latest version updated on 17 May 2018 is published on this page of the Site. All updated versions of the policy will be published on this page of the Site.

Information we may collect from you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). When you visit our Site, use the ZoomDoc App or correspond with us by phone, e-mail or otherwise you may give us information that would be classed as personal data about you and others you are acting on behalf of. We may collect, use, store and transfer different kinds of personal data about you when you do so which we have grouped together follows:

Identity Data

which includes your first name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data

which includes the consultation address you provide (which may be your work or home address), billing address, email address and telephone numbers.

Health Data

which includes any information about your health including your medical history and/or current health status including but not limited to data regarding test results, diagnoses and medications.

Financial Data

which includes your bank account and payment card details.

Transaction Data

includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data

including the type of Device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system and the type of mobile browser you use, and the Internet protocol (IP) address used to connect your computer or Device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;Profile Data which includes your username and password for any accounts set up to access our products and services, purchases or orders made by you, feedback responses.

Usage Data

which includes information about your use of the Site and the ZoomDoc App, including location information, the full Uniform Resource Locators (URL) clickstream to, through and from our Site and the ZoomDoc App (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any email address used to contact us.

Marketing and Communications Data

which includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Except for data about your health, we do not collect any Special Categories of Personal Data (as defined in GDPR) about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Keeping your data secure

We know that data security is important to you and it is therefore important to us. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions in accordance with this policy and they are subject to a duty of confidentiality.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site and the ZoomDoc App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How we collect your data

We use different methods to collect data from and about you including through:

Direct interactions. You may give us any of the categories of data identified above by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. This includes personal data you provide when you:

register to use our Site;
make a request for our products or services;
request marketing communications to be sent to you;
give us some feedback.

Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites and apps employing our cookies. Please see our cookie policy below for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as analytics providers, advertising networks and/or search information providers based inside the EU, including for example Google Analytics.

Contact, Financial and Transaction Data (if applicable) from providers of technical, payment and delivery services such as Stripe based inside the EU.

Identity and Contact Data from data brokers or aggregators such as Firebase based inside the EU.

Why we will use your data

The lawful bases for processing personal data are set out in Article 6 of the General Data Protection Regulation (GDPR). We may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below. At least one of these must apply whenever we process personal data:

Consent

You have given clear consent for us to process your personal data for a specific purpose.

Contract

The processing is necessary for a contract we have with you (for example, to process and deliver goods or services to you and to manage our relationship with you), or because you have asked us to take specific steps before entering into a contract.

Legal obligation

The processing is necessary for us to comply with a legal or regulatory obligation (not including contractual obligations).

Vital interests

The processing is necessary to protect someone’s life.

Public task

The processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.

Legitimate interests

The processing is necessary for our legitimate interests (for example to administer and maintain our Site) or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Healthcare provision

The processing of data concerning your health is necessary for us to provide you with a medical diagnosis and/or healthcare treatment.

Click here to find out more on the Information Commissioner’s Office website about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than as described below. However, where we do ask for your consent (for example in processing data relating to your health) we will do so in order to comply with the principle that any processing must be lawful, fair and transparent. Please see our terms and conditions for more information on this.

Disclosing your personal data

We may have to share your personal data with the parties below in order to provide our services to you. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Examples of our third parties include:

GPs who provide services to you via the ZoomDoc App.
Your regular GP (with your express consent or in accordance with a legal or regulation obligation)
Sub-contractors for the performance of any contract we enter into with them or you.
Analytics and search engine providers that assist us in the improvement and optimisation of our Site and the ZoomDoc App.
Any appstore provider you use to access the ZoomDoc App and your mobile network operator. Pharmacies for the delivery of medication, where you request medication delivered to your home, hotel, office or other residence you notify us of.

We may also disclose your personal data to third parties

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If ZoomDoc Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or in order to enforce or apply our terms of use and other terms of service; or to protect the rights, property, or safety of ZoomDoc Limited, GPs we make available to you to provide medical services, our customers, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The data we collect from you will be transferred to and stored on the computer servers of one or more third parties, such servers are based within the European Economic Area (“EEA“). All information you provide to us is stored on secure servers and encrypted. The data will be processed and used by us in accordance with this policy.

Cookies

Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our site.

A cookie is a small file of letters and numbers stored on your browser or the hard drive of your computer in order to enhance your experience and to provide functionality on the Site.

We use the following cookies:

Strictly necessary cookies

These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site such as your personal records and on-line payment services.

Analytical/performance cookies

These allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies

These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

We may also use:

Targeting cookies

These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and any content displayed on it more relevant to your interests.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

You may block cookies by activating the relevant settings on your browser. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for essential cookies, all cookies will expire after no more than 30 days.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased Services from us and, in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes. You can ask us to stop sending you marketing messages at any time by logging into the Site and adjusting your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase of goods or services from us.

Our Site and the ZoomDoc App may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

How long we will keep your data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We retain personal data in accordance with our policy.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to access the Information Commissioner’s Office website to find out more about these rights:

If you wish to exercise any of the rights set out above, please Contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee of £10 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.